Ending the war on drugs: Making the
case for regulation of drug markets in Latin America
and beyond

Join us to learn and share experiences on how to meaningfully engage with the
drug policy reform debate, how to talk about regulation models, messaging and
framing arguments for different audiences, and how to respond to common
concerns.

The focus will be on the debate in Latin America,
but the themes will be relevant for all reformers.

It is a guide
to making the case for drug policy and law reform in Latin
America from a position of confidence and authority, with a
particular focus on the issue of legal regulation of currently illegal drug
markets, something that is now core to the debate in the region. It is for
every policymaker, media commentator, and campaigner who not only recognises
that the ‘war on drugs’ is a
counterproductive failure that is creating catastrophic unintended
consequences, but who also wants to convince others to back reform.

It will equip
you with the constructive arguments, different approaches and nuanced messaging
needed to address the concerns and interests of diverse audiences. This will
enable you to not just win the argument, but make the new allies needed to turn
the current unparalleled momentum for reform into concrete policy change
nationally and internationally. Although the book is tailored to Latin America, the arguments it lays out are relevant for drug policy reformers globally.

Print copies are currently only available in Spanish. The English translation is coming soon, but if you can't wait, a pre-publication draft is available from info@tdpf.org.uk

“Transform/MUCD's Ending the War on Drugs: Making the Case in
Latin America workshop in Mexico
about how to argue for drug law reform in general, and legal regulation in
particular, was invaluable. It should be rolled out globally to advocates of
drug law reform, and all policymakers considering change. This education is
vital to bring about a smooth and effective transition in drug policy.”

Ambassador Edgar Guitérrez Girón, Special Mission on Drug Policy Reform for the Republic of Guatemala, 2013

“The
time has come to discuss new approaches to dealing with the problems of drugs
in the Americas.A new approach should try and take
away the violent profit that comes with drug trafficking… If that means legalising,
and the world thinks that's the solution, I will welcome it.”

Thursday, September 12, 2013

The last few weeks have been marked by several positive developments
in drug policy around the world.

The Uruguayan Parliament passed a groundbreaking bill that, subject to Senate approval later this year, will make Uruguay
the first country in the world to legally regulate the production and sale of
cannabis under government monopoly.

In the United States, Attorney General
Eric Holder announced changes in the Justice Department’s sentencing policy so that certain low-level, non-violent drug offenders; "will no longer be charged with offences that impose draconian mandatory minimum sentences."

The US Federal Government also indicated it will allow individual states to proceed with marijuana legalization, as long as they ensure production and supply are well regulated, including restricting access to minors, and preventing excess production being sold into states that have not legalized.

These important advancements come at a time when the heavy-handed tactics of the war on drugs are being increasingly questioned.
Nevertheless, for many governments the punitive war on drugs approach
continues to be used to justify a wide range of distressing and unacceptable acts that directly breach their international human rights obligations. From the use of the death penalty for drug offences, to compulsory
drug detention centres, arbitrary arrests and extrajudicial killings, the state
of drug policies is, in many countries, draconian to say the least.

Below is a selection of the most oppressive practices around the
world. They highlight the urgent need for a global shift away from criminal justice-led drug policies towards those centred around health that support rather than punish. They also underline that this shift needs to happen not just for marijuana, but for all drugs.

1. China

Official numbers regarding
death sentences and executions performed in China are a state secret, and so not readily available. Nevertheless, it is widely believed that China performs more executions than the rest of the world put together.Moreover, the conviction rate is nearly 100%, so if someone is
accused of a crime that is punishable by the death penalty, they are almost certain to receive that sentence. According to Amnesty
International, defendants often face trials where the court has already decided
a verdict and possibly a sentence, a practice that could explain why many
people are sentenced to death after trials lasting less than an hour.

Although in 2011 China removed 13 mostly economic crimes from the list for which the death penalty can be handed down, but drug offences such as trafficking remain on the list.

The “treatment” of suspected drug users in China also presents a grim picture. In theory, the country's Anti-Drug Law of June 2008 ended the programme of sentencing alleged drug users to
Re-Education Through Labour. In reality though, it effectively expanded the previous 6-12 months sentence to a minimum of 2 and sometimes 3 years in drug detention centres instead. The law also allows for a period of up
to four years of unspecified “community based rehabilitation”, in practice
allowing for up to 7 years of incarceration. The detainees are routinely
beaten, forced to work up to 18
hours a day without pay and denied medical or drug dependency treatment.
Detention takes place without trial and the Anti-Drug Law gives the police
rather than medical professionals the power to determine the “addiction” and
need for detention without any legal process or even evidence of current drug
use. A 2009 UNAIDS report estimates that at any given time approximately 500,000 people are undergoing drug detention in China.

2. Iran

The 2011 Amendments to the Anti-Narcotic Law of the Islamic Republic of Iran introduces; “the death penalty for trafficking or possessing more than 30 grams of specified synthetic, non-medical psychotropic drugs, and for recruiting or hiring people to commit any of the crimes under the law, or organising, running, financially supporting, or investing in such activities, in cases where the crime is punishable with life imprisonment”.

In 2011 80% of the
676 executions performed in Iran were of drug offenders. Only 9% of people executed for drug charges were fully identified. The soaring number of arrests for drug trafficking in recent years is in part due to international assistance to halt the flow of drugs from Afghanistan, but also because the drug laws are used to sentence political opponents of the regime.Public executions also seem to be on the rise with a four-fold increase between 2010 and 2011.

Drug traffickers usually come from the most disadvantaged sectors of
society, members of ethnic minorities and foreign nationals, mostly Afghans
trying to escape poverty by working as drug mules. A lack of transparency makes getting hard numbers on those facing execution impossible to obtain, but comments by Iranian officials suggest there may be 4,000 Afghans alone on death row for drug trafficking. According to Amnesty International; "

Most - if not all - of those condemned to death for drugs offences have faced grossly unfair trials", or have never even seen the inside of a court at all.

Although Iran, having a serious national drug problem, with more than 2 million users, has made some progress in decriminalising and providing some forms of treatment for drug users, the number of people on death row for drug trafficking offences remains staggering.

3. Viet Nam

Like in China, Vietnamese death penalty statistics are also considered a state secret. Yet reports state that in 2011 69 people were sentenced to death, 27 of them for drug smuggling. Just five executions have been officially reported.

Viet Nam also has a wide and
expanding network of compulsory drug detention centres that in practice have
nothing to do with treatment and constitute forced labour camps. Refusal to
work, violating rules or not meeting quotas results in punishment that often
amounts to torture.

Along with this increase came an expansion of the length of detention, from a minimum of three months to one year as of 2000, to four years of supposed drug treatment according to the provisions of a law passed by the National Assembly in 2009. The detention centres stem from a tradition of “re-education through labor” camps for drug users and sex workers established after 1975, and formed part of the governmental campaign to eradicate “social evils” including drug use that gained momentum in the mid-1990s.

In detention “treatment” involves working six days a week processing cashews, sewing garments, manufacturing garments and other items and working in construction. Both unpaid work, and work for a fraction of the Vietnamese minimal wage is common. What is more, the centres often deduct food, lodging and “managerial fees” from the pay, and upon release people sometimes find themselves indebted to the centres. The law also states that children aged 12-18 who are addicted to drugs can be detained in the centres for up to two years and are also required to work. Legal regulations require that all drug addicts must report their dependency to the local authorities or their workplace, and register for obligatory “detoxification”. Families are also required to report their relatives for drug addiction to the authorities. The vast majority of detainees are heroin users.

4. Cambodia and Laos

Compulsory drug detention centres are also prevalent in neighbouring Cambodia and Laos. The Government of the Lao People’s Republic declared that it aims to make the country “drug free” by 2015. Achieving this goal includes village militias detaining drug users, and family members being encouraged to report each others drug use.

In both countries these centres have very little to do with treatment, and are often used as dumping grounds for individuals deemed as “undesirable”. People locked up include drug users (casual, past or in genuine need of treatment), the homeless, beggars, street children, sex workers and people with mental disabilities or illness. In both countries the majority of detained users use amphetamine type stimulants, with some addicted to heroin. The vast majority are sent to the centres by the authorities, with large numbers detained at the request of their families, who are often required to pay for “treatment”.

In 2011 in Laos Human Rights Watch reports mention at least eight drug detention centres throughout the country, with the biggest one - Somsanga located in the capital Vientiane.

This video gives
a powerful account of the
struggle of Thai drug user activists and the 2003 war
on drugs launched by Prime Minister Thaksin Shinawatra, that entailed almost
3000 extra judicial killings. In 2007 an official investigation found that over
50% of the victims had no connection to drugs whatsoever.

As the International Harm Reduction Association's Death Penalty for Drug Offences report states, in the first six months of 2012 there were at least 45 executions in Saudi Arabia, at least 16 of them for drug offences including a minimum
of 3 for cannabis. It is known that foreigners, a lot of them from Pakistan, are disproportionately sentenced to death.

There are an estimated 1.8 million injecting drug users in Russia - one of the highest levels in the world. About a decade ago 100,000 people in Russia were HIV positive, by 2012 that number had jumped to over 1 million. Russia is at the epicentre of the fastest growing HIV epidemic in the
world - yet the response of its authorities includes restricting precisely the kind of harm reduction measures that have been proven to work all over the globe including needle exchange
programs, and opposition to the use of
methadone and buprenorphine as well as attacks on NGOs providing crucial assistance
to drug users, such as the Andrey Rylkov Foundation.

Saturday, September 07, 2013

The first system of state government regulated production and supply of cannabis for non-medical use came one step closer this week, with the publication by the Washington State Liquor Control Board of its latest draft rules for the production and supply of marijuana. (See below for highlights)

These proposed new rules appear to meet the requirements laid down by US Attorney General Eric Holder in his recent announcement that the Federal Government will allow individual states to proceed with marijuana legalization, as long they ensure production and supply are well regulated, including restricting access to minors, and preventing excess production being sold into states that have not legalized.

We also find the detail fascinating, shaped as it is by a combination of the requirements of the wording of the ballot initiative that voters passed; existing federal and state regulatory frameworks and laws they must accommodate and comply with, for example on packaging, advertising, intoxicants etc; the Federal Government's specific requirements; and last but not least, the rapidly changing US political and cultural landscape too.

Included in that changing landscape is the fact that cannabis legalisation ballot initiatives significantly increase the number of young voters who make it to the ballot box, something that favours Democratic candidates (by and large). As a result, with over half of all Americans now supporting marijuana law reform, and 83% saying the war on drugs has been lost, for Democrats at least, cannabis law reform is no longer a third rail issue - it is a vote winner, whether Obama can say so publicly or not. How do the Republicans respond to this? Calling for the Federal Government to stamp all over states rights is not acceptable for most of them, and with even former Presidential Candidate John McCain saying"Maybe we should legalize" marijuana, surely the game is up.

Internationally, these changes combined with a general reduction in international influence means that the US can no longer effectively dictate a global prohibitionist approach to cannabis, as underlined by Uruguay's bold moves. With legislators in many other regions expressing support for Uruguay, or interest in legalizing cannabis in their own cities or countries, it is clear we are not at a tipping point on ending cannabis prohibition. We have passed it.

September 4, 2013

LCB Rulemaking Objective

Creating a tightly controlled and regulated marijuana market;

Including strict controls to prevent diversion, illegal sales, and sales to minors; and

Providing reasonable access to products to mitigate the illicit market.

Personal criminal history completed by applicant. Risk of license forfeiture if incomplete or incorrect.

Fingerprinting of all potential licensees

Background checks of license applicants and financiers

Point System

The LCB will apply a disqualifying point system similar to liquor

All applicants must disclose all arrests and/or convictions

Non-disclosure of arrests regardless of conviction will result in point accumulation

License Limits

Licensed entity or principals limited to three producer licenses

Licensed entity or principals limited to three processor licenses

Licensed entity or principals limited to three retail licenses.

Multiple-location licensees not allowed to hold more than 33 percent of the allowed licenses in any county or city.

Production Limits

The maximum amount of space for marijuana production is limited to two million square feet.

Applicants must designate on their operating plan the size category of the production premises and the actual square footage in their premises that will be designated as plant canopy.

There are three categories:

Tier 1: Less than 2,000 square feet;

Tier 2: 2,000 square feet to 10,000 square feet;

Tier 3: 10,000 square feet to 30,000 square feet.

The LCB may reduce a licensee’s or applicants’ square footage designated to plant canopy for the
following reasons:

If the total amount of square feet for production of all licensees exceeds the two million square feet maximum, the LCB will reduce the allowed square footage by the same percentage.

If 50 percent production space used for plant canopy in the licensee’s operating plan is not met in the first year of operation, the board may reduce the tier of licensure.

If the total amount of square feet of marijuana production exceeds two million square feet, the LCB may reduce all licensees’ production by the same percentage or reduce licensee production by one or more tiers by the same percentage.

Maximum Allowable Amount on Licensed Location

Producer license

Outdoor or greenhouse: 125 percent of its year’s harvest

Indoor: six months of its annual harvest

Processor license

Six months of their average useable marijuana (plant material); and

Six months average of their total production (finished product).

Retailer license

Four months of their average inventory

Licensed Location: 1000 foot Measurement

Distance will be measured along the most direct route over or across established public walks, streets,
or other public passageway between the proposed building/business location to the perimeter of the
grounds of: an elementary or secondary school, playground, recreation center or facility, child care
center, public park, public transit center, library or arcade where admission is not restricted to those
age 21 and older.

Costs and Fees

$250 application fee

$1,000 annual renewal fee

Additional fees for background check and filing for local business license

Taxes

License applicants must submit a signed attestation that they are current on taxes owed to the Washington State Department of Revenue

Insurance

Licensees are required to carry commercial liability insurance.

Public Safety

Producer Structures

Rules allow producer operations in secure: indoor and outdoor grows as well as greenhouses

Traceability

LCB will employ a robust and comprehensive traceability system (software) that will trace product from seed/clone to sale.

LCB enforcement can match records to actual product on hand

Background Checks

Personal criminal history form

Fingerprinting of all potential licensees

Background checks of licensees and financiers

Point System

LCB will apply a disqualifying point system similar to liquor (exceptions for possession)

Strict transportation and record keeping requirements (no third party transport of product)

Hours of operation limited to 8:00 a.m. to 12:00 a.m.

Advertising Restrictions

Law restricts advertising within 1,000 feet of schools, public parks, transit centers, arcades, and other areas where children are present.

May not contain statements or illustrations that are false or misleading, promotes overconsumption, represents that it has curative or therapeutic effects, depicts a child or may be appealing to children

All advertising must contain two statements: a: “This product has intoxicating effects and may be habit

forming.” And, b) “Marijuana can impair concentration, coordination, and judgment. Do not operate a vehicle or machinery under the influence of this drug.”

Friday, August 02, 2013

The Uruguayan Parliament yesterday voted to pass a Bill that will legalise and regulate the production, sale, use and personal cultivation of cannabis for non medical use by adults. The Bill will now pass to the Senate for a vote (and possible amends) in October before returning to the Congress before final approval from the Board of Deputies. Although these are potential stumbling blocks, the Congress vote was 'the big one' and it looks highly likely that the Bill will now pass into law later in the year.

At this point Uruguay will be the first national government in the world to have voted through a new law to legalise and regulate cannabis - or indeed any drug prohibited by the UN drug conventions. To this extent the change differs from the groundbreaking developments in Washington and Colorado, where the legalisation measures were passed by popular vote (via ballot initiatives), with both local State and Federal governments firmly opposed. By contrast, Uruguayan public opinion is not yet behind the legalisation move, with Uruguayan politicians tackling drugs by showing something alien to most governments around the world: leadership.

Uruguay's House of Representatives historic vote for change

Summarised details of the Bill are as follows (with thanks to Hannah Hetzer):

The State will assume control and regulation of all activities relating to import, export, planting, growing, production, storage,
commerce and distribution of cannabis and its derivatives.

Any plant from which psychoactive drugs can be derived
will remain prohibited with the following exceptions:

For scientific research or medical use. These must be authorised by the
Ministry of Public Health and will be under its direct control.

Cannabis. This must be authorised by the Institute of Regulation
and Control of Cannabis (IRCCA) and will be under its direct control.

Psychoactive cannabis (THC equal or higher to 1%
of its volume) will be under the direct control of the IRCCA. Non-psychoactive
cannabis (hemp) will be under the direct control of the Ministry of Livestock,
Agriculture and Fisheries.

Domestic cultivation of cannabis for personal
consumption will be permitted up to six plants and its product should not
exceed 480 grams.

Social clubs for cannabis growers (similar to those in Spain) will be controlled by the IRCCA.
They may have a maximum of 100 members and may plant a maximum of 99
plants.

Cannabis commerce licenses will be
given to pharmacies authorised by the Ministry of Public Health. The authorised
pharmacies will require users to present either a medical prescription or they
must be included in the registry of users.

All unauthorised cultivation must be destroyed
with an intervention by a judge. All unauthorised production, importation,
exportation, transit, distribution, and sale will be penalised with 20 months
to 10 years imprisonment.

Purchase for personal consumption will be understood to be up
to 40 grams of cannabis per month.

The IRCCA will have a register of users, home
growers and membership clubs. The registry will be free and will solely be used
to ensure traceability and control of cultivation and use. The information will
considered confidential data, conforming to the associated norms in article 18 of
Law N° 18.331, of August 11, 2008.

The National Integrated Health System (SNIS)
must implement policies pertaining to the promotion of health, the prevention
of problematic use of cannabis, and provide adequate advice, guidance and
treatment for problematic cannabis users.

In cities with more than 10,000 inhabitants,
mechanisms will be installed for Information, Advice, Diagnosis, Referral,
Attention, Rehabilitation, Treatment and Integration of those affected by
problematic drug use. These will be managed by the Junta Nacional de Drogas,
which can sign agreements with departmental and municipal governments and
NGOs.

The National System of Public Education (SNEP)
must have education policies for the promotion of health and the prevention of
problematic cannabis use from the perspective of the Development of Abilities for Life (Habilidades para la Vida) and in the
framework of risk management and harm reduction policies. These education
policies must be included in the curricula in Primary, Secondary and Professional
Technical Education, with the aim of preventing the harms produced by drug
consumption, including cannabis. In the “Prevention of Problematic Drug Use”
included in the curricula, special spaces will be given to driving education
and traffic accidents caused by the consumption of drugs.

All forms of publicity, indirect publicity,
promotion or sponsorship of psychoactive cannabis products will be prohibited
including in all types of media: written press, radio, television, cinema,
magazines, posters, pamphlets, emails, etc.

The Junta Nacional de Drogas must realise
education, outreach and awareness campaigns on the risks, effects, and
potential harms of the use of drugs.

The measures put forward in article 3º of Law Nº
18.256, of March 6, 2008 on protection of public spaces will be applied.

Those under age 18 will not be permitted to
access psychoactive cannabis for recreational use. Violation of this will be
penalized according to Decree-Law N° 14.294, in the drafting given in Law N°
17.016.

Driving of any vehicles when the THC level is
above the amount to be established will not be permitted. The Junta Nacional de
Drogas will provide the necessary training, advice and supplies to officials
especially designated to this, from the Ministry of the Interior, Ministry of
Transport and Public Works, Ministry of Departmental Governments, Ministry of
Municipal Governments, and Ministry of National Maritime, with the aim of
realizing the aforementioned control. These tests will be via blood tests or
other clinical or paraclinical tests, via the SNIS (National Integrated Health
System) providers. Drivers that violate this limit will be penalised by the
sanctions established in article 46 of Law 18.191 of November 14, 2007.

In addition to regulating cannabis, the IRCCA
will be in charge of promoting actions relating to risk and harm reduction
associated with the problematic use of cannabis, according to the policies
defined by the Junta Nacional de Drogas and in coordination with national and
departmental authorities, as well as monitoring compliance. The IRCCA will
coordinate and be linked to the Executive Power through the Ministry of Public
Health.

The Junta Nacional de Drogas will be in charge
of setting national policies regarding cannabis with the advice of the
IRCCA.

The IRCCA will include a member from each of the
following: the National Drug Board; the Ministry of Livestock, Agriculture and
Fisheries; the Ministry of Social Development; and the Ministry of Public
Health. The National Advisory Board of the IRCCA will include representatives
from the following: Ministry of Public Health, Ministry of Education and
Culture, Ministry of the Interior, Ministry of Economy and Finances, Ministry
of Industry, Energy and Mining, the University of the Republic, the membership
clubs, the home growers associations, and the licensees.

Within the Presidency of the Republic, a Special
Unit for Evaluation and Monitoring of this law will be created, comprised of
staff specialised in policy evaluation and monitoring. It will be independent
and will submit annual reports, which must be considered by the organisms and
bodies responsible for the execution of this law.

Check out this brilliant animated short film from Regulación Responsable explaining how the new system will work (sadly in Spanish only - but an English version is coming soon)

Transform are delighted that Uruguay has taken this sensible and serious approach to legally regulating cannabis, and we're pleased to have played a part in assisting the country's government in formulating the regulation framework. Our Latin American Programme Manager, Lisa Sanchez, and our Senior Policy Analyst, Steve Rolles, were invited to advise on the policy last year as one of a series of expert delegations. Hosted by the Junta Nacional de Drgas, Steve and Lisa briefed and discussed relevant issues with law makers, medical authorities, various MP groupings and committees, the full Uruguayan cabinet and prime minister, President Mujica, local civil society groups, and the media.

Coverage of Transform's Uruguay visit in La Republica (Sept 2012)

It was welcome to see how most of Transform's suggestions have been taken on board, and whilst we don't agree with everything in the Bill (we recommended against the registration scheme for example) it is important to stress how Uruguay approached the challenge of developing it in a thorough, methodical and responsible evidence-based fashion, taking guidance from a range of local and international expertise, and involving a range of stakeholders in an open and transparent process. As well as demonstrating leadership on the international stage, they have provided a useful template for how cannabis regulation policy can and should be developed.

Steve and Lisa from Transform - at the Uruguayan Parliament in October last year, having given evidence to the Home Affairs committee on drugs October 2012

This commitment to 'getting it right' was again reflected this April when the Uruguayan Government hosted a week long event involving a 3 day seminar and discussion on the proposals with 40 local and international experts, followed by a series of public hearings with the experts and politicians across the country. Steve was invited back to Uruguay to participate.

Today we are fundraising for our new publication, 'How to
Regulate Cannabis: A Practical Guide'.

It will show policy makers how a regulated cannabis market can take control away from organised criminals and put it back in the hands of
the government. The models we are proposing will make better use of taxpayers'
money and safeguard young people, communities and public health.

For more detail about the book see our dedicated Justgiving page for
this project.

We have already raised half the money for the book, and
we’re now seeking £5,000 more to match it and finish the job. The book is due to be
launched in October, so we’ve given ourselves a month to raise the
match-funding.

Monday, July 08, 2013

Professor Averil Mansfield, Chair of the British Medical Association, speaking at the Count the Costs health event

Transform, as the leading coordinator of the Count the Costs initiative, held a lunch-time meeting last month for some world-leading health professionals and NGOs. The event included presentations from Professor Averil Mansfield, Chair of the British Medical Association Board of Science; Anton Olfield-Kerr, Head of Policy of the International HIV/AIDS Alliance; and Martin Drewry, Executive Director of Health Poverty Action.

Attendees at the event came from a wide range of organisations, including The Faculty of Public Health, The Royal College of Nursing, Addaction, Médecins du Monde, the National Aids Trust, the People's Health Movement and Save the Children.

The lunch time session started with a presentation from Professor Mansfield, who freely admitted to being strongly influenced by the launch of Transform’s flagship publication, 'After the War on Drugs: Blueprint for Regulation'. At that time [2009] she was President of the BMA and it was not until she became Chairman of the BMAs Board of Science that she was able to take the lead on this issue. The result was a publication, produced by the BMA, entitled ‘Drugs of dependence: The role of medical professionals’, which looked at alternative approaches to drug policy and highlighted the need to deal with drugs as a health issue.

Professor Mansfield’s presentation was followed by talks from representatives from Health Poverty Action and the International HIV/AIDS Alliance, who stressed, among other things, the importance of more NGOs engaging with the drugs issue, in an effort to generate pressure from civil society in the lead up to the United Nations General Assembly Special Session (UNGASS) on Drugs in 2016.

The event was an informal, off-the-record discussion and we were delighted by the number of newcomers to the debate who attended. We have received very encouraging feedback and hope it will lead to a number of new supporters and joint initiatives going forward, as we build up the campaign in advance of UNGASS 2016. The event was also mentioned by Tom Chivers, who wrote a great article on drug policy in The Daily Telegraph the following day.
You can also read the health briefing that we developed for the campaign here.

The dinner was the second in a series of outreach events that we are planning over the coming year in an effort to mainstream support for our Count the Costs campaign. We are delighted that the campaign now has over 100 supporters, a full list of which can be found here.

This blog has many contributors; blog entries or comments posted to blog are not necessarily the views of Transform Drug Policy Foundation. For official comment or position statements on any given topic, or with any feedback or queries, please contact Transform. Transform Drug Policy Foundation is a registered charity No. 1100518